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Penalty Order Timing u/s 275(1)(c): Must Be Issued Within Six Months of Penalty Action Initiation.

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....Levy of penalty u/s 271C - Period of limitation - In the present case, since penalty u/s 271C has not been initiated during the course of any proceedings, first part of sec. 275(1)(c) would have no application and it is only the second part which would apply. Thus the penalty order ought to have been passed within a period of six months beginning from the end of the month in which the action for imposition of penalty was initiated. - AT....